Planning Reform: Supporting the high street and increasing the delivery of new homes NLA response

A new permitted development right to support housing delivery by extending buildings upwards to create additional new homes

Question 1.9: Do you think there is a role for a permitted development right to provide additional self-contained homes by extending certain premises upwards?

Yes

Yes, allowing for a permitted development right by extending buildings upwards will be able to deliver additional homes, particularly in high density housing areas such as London. However, development and planning for additional homes should consider the importance of open spaces, as well as considering there may be restrictions when building up, including whether the building is physically capable of extension and whether the architectural value is diminished. Furthermore, not only should the physical practicalities of extending upwards, but due to the costs involved rather than the burdens of securing planning permission.

Question 1.10: Do you think there is a role for local design codes to improve outcomes from the application of the proposed right?

Yes

Yes, local design codes could improve outcomes, by allowing the local community to contribute to the buildings design. Secondly, the local planning authority would be able to set design criteria appropriate to the character of an area and plan for any infrastructure requirements of the new homes.

Question 1.11: Which is the more suitable approach to a new permitted development right:

a. that it allows premises to extend up to the roofline of the highest building in a terrace; or

b. that it allows building up to the prevailing roof height in the locality?

b. Prevailing roofline

Neither option should be prioritised. A one size fits all building approach cannot be applied nationally, the character of an area should always be used as the deciding basis or approach to development.

Question 1.12: Do you agree that there should be an overall limit of no more than 5 storeys above ground level once extended?

Yes

In terms of meeting housing targets, having no limit would be by far the most beneficial option. However, if the Government is to have no overall limit, it is critical that guidance is set out on how to achieve a one size fits all development right, which could easily be considered unworkable. Furthermore, in regard to the approval processes, the complex prior approval that would be required to protect neighbours, as well as the character and amenity of an area would result in a permitted development right that would be no less difficult and complex than a planning application.

Question 1.14: Do you agree that, separately, there should be a right for additional storeys on purpose built free standing blocks of flats? If so, how many storeys should be allowed?

Yes

We agree that there should be a right for additional storeys on purpose built free standing blocks of flats, however the limit should be decided by the relevant local authority. Broadly speaking, we would agree with the Government’s proposal outlined in the consultation that due to likely impacts on local amenities there should be a five-story limit, with proposals for anything higher requiring a planning application.

Question 1.15: Do you agree that the premises in paragraph 1.21 of the consultation document would be suitable to include in a permitted development right to extend upwards to create additional new homes?

Yes

Yes, we would support the incorporation of a range of categories outlined in paragraph 1.21 into C3 residential use, providing minimum standards are met and guidelines are enforced.

Question 1.16: Are there other types of premises, such as those in paragraph 1.22 of the consultation document that would be suitable to include in a permitted development right to extend upwards to create additional new homes?

Yes

Yes, with a national shortage of housing, particularly in high density areas, innovative solutions are needed to overcome this. A common opposing argument to development is the lack of amenities near new housing to justify it being built. As the consultation outlines, we agree with the idea that this problem could be solved by allowing development of premises such as health centres and buildings used for community and leisure purposes to be included in a permitted development right.

Question 1.17: Do you agree that a permitted development right should allow the local authority to consider the extent of the works proposed?

Yes

Yes, local authorities should have as much consideration as possible available to them, it would not be helpful to deny them any input into the process.

Question 1.20: Should a permitted development right also allow for the upward extension of a dwelling for the enlargement of an existing home?

Yes

If so, what considerations should apply?

When considering the enlargement of an existing home, considerations should be taken regarding the impact it will have on the property’s energy efficiency, as well as extensions concerning the roof space, as well as current extension guide which mandate a maximum of three metres from the property, or four metres for a detached house.

Making permanent two time-limited permitted development rights

Question 1.24: Do you agree that the existing time-limited permitted development right for change of use from storage or distribution to residential is made permanent?

Yes

As well as encouraging more conversion of residential properties, from a practical perspective, many landlords would benefit from the option to make larger single storey rear extensions to properties in their portfolio.

Question 1.25: Do you agree that the time-limited permitted development right for larger extensions to dwelling houses is made permanent?

Yes

Allowing the time-limited permitted development right for larger extensions to be made permanent would allow more ability to build higher density homes.

Supporting housing delivery by allowing for the demolition of commercial buildings and redevelopment as residential

Question 1.27: Do you support a permitted development right for the high-quality redevelopment of commercial sites, including demolition and replacement build as residential, which retained the existing developer contributions?

Yes

The NLA supports policies which would encourage owners to change use rather than redevelop the site, leading to the delivery of more high-density homes, as long as existing developer contributions are maintained. We have also supported government plans to introduce a permitted development right that would allow commercial buildings to be demolished and replace with residential properties.

Impact Assessment

v. Making permanent the right for the change of use from storage to residential

As outlined in our answer above, we support policies which would encourage owners to change use rather than redevelop the site, leading to the delivery of more high-density homes, as long as existing developer contributions are maintained. We have also supported government plans to introduce a permitted development right that would allow commercial buildings to be demolished and replace with residential properties.